We have seen that our City got a grant to “restore” Reedy Creek in order to remove pollutants that already are being removed. As well, we have seen that they plan to clearcut park property and dig up a part of Reedy Creek that now helps improve water quality.
Thus, we see:
- DPU has no record as to how much of the sediment or phosphorus to be removed by the project already is being removed by the sediment traps (“forebays”) at Forest Hill Lake.
- DPU has no record showing that it disclosed, or even discussed disclosing, to DEQ that it was asking for grant money to remove pollutants that the taxpayers already had built a facility to remove.
- There are no records regarding dissolved oxygen. As to the “see attached file” portion of this response:
- See below as to the attached files. Neither discusses dissolved oxygen. Thus neither document contradicts the first part of the response: They have no record discussing the effect of the project on the current dissolved oxygen removal in the project area.
- See below as to the “discussion” of a rain garden alternative to the project.
- Aside from the rain garden “discussion” (at the consultant, not at DPU), DPU has no record as to consideration of alternative sites on Reedy Creek or elsewhere.
The attachment mentioned in the last item is a PowerPoint presentation:
The fourth slide of that presentation, mentioned in the request, is this:
So we see that DPU’s Grace LeRose says to the public that “Integrated Watershed Management in Richmond” somehow is, or should be, related to applying funds to get best environmental gain. But DPU has no records on that subject as to the Reedy Creek project.
The Attachments: There are two attachments to the response.
The first is an email from February 23 of this year, 4 months after the project contracts were to be awarded, from the City’s engineering firm on the project. See a copy here. The date is interesting: It is the day of the public meeting in Forest Hill regarding the project. The implication is that, as the absence of other documents demonstrates, DPU had not given any thought at all to alternatives.
The email reports a back-of-the-envelope calculation that it would take rain gardens on 55% of the residential properties on the Reedy Creek watershed to obtain the phosphorous removal calculated for the project. From the date, we see that the City did not have even this morsel of information when it decided to clear six acres of native forest (Bill Shanabruch of the Coalition tells me that all but three of the trees to be killed are natives) and dig up Reedy Creek to remove pollutants that the sediment traps in Forest Hill lake already are removing. In short, the consultant thought briefly about rain gardens, but DPU did not. As well, we see that the City utterly failed to consider runoff from businesses (e.g., along Midlothian Tpk.) or other alternatives to the project before obtaining the grant and applying for the permits.
As another back-of-the-envelope calculation: If the City spent its $635,000 on the 1,760 calculated rain gardens ($360 per rain garden), they could achieve the same effect without clearcutting six acres of parkland. Indeed, I’ll bet a $100 or $200 tax abatement would generate that many rain gardens at a much lower cost.
When I mentioned rain gardens to Bill Shanabruch, he wrote: With regard to rain gardens – they actually cost quite a lot more than $360 if they are professionally installed. Of course, there are lots of variables: size, soils, plants, etc. On the face of it, the city is correct that rain gardens are not as cost-effective as stream restoration in terms of getting Bay TMDL credit. But there are many other factors to consider. Cost-share and/or sweat equity programs for residential rain gardens would greatly reduce the cost to the city. Then, there is also grant money available out there. And there are lots of non-profits and volunteers to tap into. And there are no maintenance costs because you make the private property owner sign a maintenance agreement. But most of all, rain gardens solve the actual problem of too much stormwater volume and the pollutants carried. I could go on and on about the benefits. As I recall, EPA has a pretty good analysis of the benefits of green infrastructure which only become apparent when one looks at urban areas holistically and stop bean-counting for one issue.
The second attachment is a copy of the City’s application to DEQ for a Stormwater Local Assistance Fund grant. See a copy here.
- The application seeks $635,000 to match the same amount of City funds.
- The application lists Reedy Creek, not the James or the Bay, as the waterbody “impacted by stormwater runoff being addressed by the project.”
- Nonetheless, the application avers that “The downstream portion of Reedy Creek and the James River will also benefit in terms of water quality from this proposed project.” The application utterly fails to mention the existing sediment traps in James River Park that are downstream, close to the project area.
- Page 8 of the application is a summary of the City’s Stormwater Facilities Improvements budget, whose purpose is “[t]o complete the necessary replacement and upgrades to the stormwater facilities.” It seems that, to DPU, the portion of Reedy Creek running through a native forest in a City park behind Wythe High School is a “stormwater facility.”
DPU later sent me a link to the City’s TMDL Action Plan. The Reedy Creek discussion, p. 4-2, does not add anything new.
On this record, it is fair to conclude that:
- DPU selected and designed this project without any consideration of alternatives;
- DPU applied for and received $635,000 from DEQ without disclosing that the pollutant removal to be performed by the project already is largely or entirely performed by the sediment traps at Forest Hill Lake;
- NOTE: A kind reader reminds me that the DEQ grant is approved but won’t be paid until all the required permits (the one I know about is the Corps of Engineers) have issued.
- DPU did not consider the environmental effect as to dissolved oxygen of the creek in its current condition.
- Ms. LeRose of DPU tells the public about “integrated watershed management” and application of funds for best environmental gain but DPU has no record of either with respect to the Reedy Creek project.
The term for a government project to spend our money with no prospect of benefit is “boondoggle.” This one would spend $1.27 million of your and my tax money to remove pollutants that we already have paid for sediment traps — and are paying for sediment trap cleaning — to remove. And, at least by omission, they lied to DEQ to get half the money for the project. And DPU’s LeRose tells the public one thing while DPU does another. “Boondoggle” probably is too kind a word. “Mendacious Boondoggle” comes closer to being accurate.
P.S. Due, probably, to a dustup caused by the City’s arbitrary email spam filter, DPU has not yet responded to the last item in my requests:
All records that establish or comment upon the schedule for the Reedy Creek project as related to the schedule in slide 7 of the attachment.
The attachment was another LeRose Powerpoint.
Slide 7 says:
Slide 6 tells us that the blue squiggles stand for “Watershed Management Plan, Set goals, Identify sources of pollution.” We already have seen that DPU did none of that in this case.
As well, although the slide title speaks of “Stakeholder Involvement,” the slide body is silent on that subject. I’ll be interested to see what DPU actually says on the subject of public involvement.
And, given that they have no dissolved oxygen information and, apparently, no information about the effect of Forest Hill Lake on sediment or phosphorus, I’ll be interested to see their plans for post-permit monitoring and reporting.
Your tax dollars at “work.”